Tax Controversy and Tax Litigation

IRS Collection Alternatives

Installment Agreement (IA).

Generally, the maximum length of time for which IRS will accept payment is 72 months.

Offer-in-Compromise (OIC).

An OIC allows you to settle your tax debt for less than the full amount you owe. It could be a legitimate option if you cannot pay your tax liability in full, or if paying in full would create a financial hardship. An OIC is based on your financial condition and ability to pay at time of submission and it must be accompanied by extensive documentation, including financial statements. The Offer amount can be paid in a lump sum, in installments, or a combination of the two.

Current Not Collectible (CNC).

If IRS determines that you cannot pay all or some of your tax debt due to an economic hardship, IRS may temporarily delay collection until your financial condition improves.

Full pay.

Paying in full, whether in a lump sum or over several months may prevent the filing of a tax lien or other enforced collection action, as long as you comply with the terms of your agreement.

Tax Return Preparation

We prepare all tax returns, business and personal. For those tax collection clients who need returns prepared, we are their convenient one-stop shop.

Liens and Levies

A levy is a seizure of your property to satisfy a tax debt and will take property to satisfy the debt. A lien is a claim used as security for the tax debt.

Before IRS can take collection actions such as liens on real estate, seizure of property, levies, or garnishments, the IRS must issue to the taxpayer a “Final Notice of Intent to Levy and Notice of Your Right To a Hearing,” allowing up to 30 days from the date of the Final Notice to pay the debt in full or to find another solution. A timely filed protest can stop the levy and allow us to try to resolve your case.

If your assets have been seized, it is important that you immediately contact competent counsel to timely and effectively defend your rights to appeal or protest.

Report of Foreign Bank and Financial Accounts (FBAR)

Failure to disclose on an annual basis your foreign accounts, foreign assets and earnings is a violation of U.S. tax law that could be regarded as criminal in nature. There are extreme penalties for failing to properly report. We help individuals with foreign disclosure problems and assist them regarding the Offshore Voluntary Disclosure Initiative and completing the necessary, complicated forms (i.e., Foreign Bank Account Reports (FBARs).

Audit

You may not have responded to an earlier IRS notice and IRS may have assessed the liability based on certain assumptions. You may be able to ask the IRS to reconsider the assessment. Some acceptable reasons may include: you did not appear for an audit; you moved and did not receive the IRS correspondence; you submitted documents that were not considered; or you have new documentation to present.